## Facts

- Thomas Linden, Jr. was severely injured when a CNH-manufactured bulldozer rolled over and he was ejected from the cab.
- Linden alleged product defects involving the bulldozer’s rollover protection system and the seatbelt assembly, including claimed manufacturing defects in the seatbelt buckle.
- Linden sued CNH in a products-liability action under Iowa law; a separate seatbelt manufacturer was dismissed from the case on limitations grounds and was not part of the appeal.
- At trial, the district court granted judgment as a matter of law for CNH on certain manufacturing-defect theories.
- The remaining claims were submitted to a jury, which returned a verdict for CNH.

## Issues

1. Whether sufficient evidence supported Linden’s manufacturing-defect theories to avoid judgment as a matter of law, including proof of deviation from specifications and causation.
2. Whether the district court abused its discretion in evidentiary rulings concerning expert testimony and related proof.
3. Whether the jury instructions misstated applicable products-liability law or burden of proof and, if so, whether any error was prejudicial.
4. Whether dismissal of a prospective juror for cause prejudiced Linden’s right to a fair and impartial jury.

## Decision

- The Eighth Circuit affirmed the judgment for CNH.
- The court held the directed verdict was proper because Linden did not present evidence from which a reasonable jury could find a manufacturing deviation in the relevant product and that the deviation caused his injuries.
- The court found no reversible error in the challenged evidentiary rulings; any arguable error did not affect Linden’s substantial rights.
- The court concluded the jury instructions, considered as a whole, fairly submitted the issues and did not warrant reversal.
- The court rejected the jury-selection challenge because Linden did not show prejudice from the dismissal of the prospective juror.

## Legal Principles

- Judgment as a matter of law is appropriate when, viewing the evidence favorably to the nonmovant, no reasonable jury could find for that party on required elements.
- Under Iowa products-liability law, a manufacturing-defect claim requires evidence that the product deviated from intended design/specifications (or from otherwise identical units) and that the deviation proximately caused the injury.
- Appellate review of evidentiary rulings is for abuse of discretion; reversal requires a showing that an error affected substantial rights.
- Jury instructions are reviewed as a whole; an instructional error warrants reversal only if it prejudices the complaining party’s substantial rights.
- A jury-selection ruling warrants relief only upon a showing of prejudice affecting the party’s right to an impartial jury.

## Conclusion

The Eighth Circuit left intact CNH’s defense verdict, holding that Linden’s proof did not support a manufacturing-defect submission to the jury and that his remaining challenges—evidence, instructions, and juror dismissal—failed because he could not show prejudicial error.


Linden v. CNH Am., LLC, 673 F.3d 829 (8th Cir. 2012)